The state of Arkansas imposed term limitations through Amendment 73, a ballot measure that prohibited the listing of any person who served the maximum terms allowed in the U. S. House or Senate on the general election ballot. Soon after the measure was adopted in 1992, Bobbie Hill, the League of Women Voters, and U.S. Representative Ray Thornton filed suit in Arkansas state court alleging that Amendment 73 violated Article I, sections 2 and 3 of the U.S. Constitution.

On May 22, 1995, the Supreme Court decided, in U.S. Term Limits, Inc. v. Thornton (514 U.S. 779), that the states could not add to or change the qualifications listed in the U.S. Constitution for those elected to Congress. The Supreme Court ruled that the qualifications listed in the Constitution are inclusive, and therefore no state could impose additional qualifications either directly or indirectly.